KUMAR BABBAR
Signing Date:12.02.2025
17:40:12
(hereinafter as the "OCD") and the said investment was done between
October, 2021 and March ... written opinion was obtained wherein it was observed
that the infusion of OCDs were likely to disturb the leverage ratio of the
ECL and hence
KUMAR BABBAR
Signing Date:12.02.2025
17:46:31
(hereinafter as the "OCD") and the said investment was done between
October, 2021 and March ... written opinion was obtained wherein it was observed
that the infusion of OCDs were likely to disturb the leverage ratio of the
ECL and hence
against the issuance of Optionally Convertible Debentures
(hereinafter as the "OCD") and the said investment was done between
October, 2021 and March ... written opinion was obtained wherein it was observed
that the infusion of OCDs were likely to disturb the leverage ratio of the
ECL and hence
these funds have been given under the garb of subscription of the
OCDs (Optionally Convertible Debentures) and CCDs (Compulsorily Convertible
Debentures) carrying 0.01% interest rate ... Group and in turn received investments in the garb of subscription of OCDs
or CCDs.
4.2. The AO was of the firm belief that
Convertible Debentures (NCDs),
Compulsory Convertible Debenture (CCDs) and Optionally Convertible
Debenture (OCDs) issued by its Associated Enterprises (AEs) in India and
during the year ... which
pertained to interest earned on CCDs/ OCDs, was offered to tax @ 15% as
prescribed under Article 11 of India-Singapore Tax Treaty. During
MALABAR PROVINCE, OCD
REPRESENTED BY PROVINCIAL, MOUNT CARMEL PROVINCIAL
HOUSE, COTTON HILL, THIRUVANANTHAPURAM DISTRICT,, PIN -
695014
6 THE ARCHBISHOP
ARCHEPARCHY OF CHANGANACHERRY, SYRO- MALABAR CATHOLIC ... HOUSE, CHANGANACHERRY, KOTTAYAM
DISTRICT, PIN - 686101
7 FR. SEBASTIAN KOODAPPARAMBIL OCD
FORMER PROVINCIAL, MOUNT CARMEL PROVINCIAL HOUSE,
COTTON HILL, THIRUVANANTHAPURAM DISTRICT
only)
in appellant no. 1 against the issuance of optionally convertible debentures
(OCD's). The appellants apprehending that the investment to the tune ... consequent issuance of OCDs may topple the
leverage ratio took a legal opinion from A. Abhinav and Associates Company
Secretary which was accordingly given
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